McGhee v. Nottingham

CourtDistrict Court, S.D. Illinois
DecidedMarch 1, 2022
Docket3:21-cv-00678
StatusUnknown

This text of McGhee v. Nottingham (McGhee v. Nottingham) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McGhee v. Nottingham, (S.D. Ill. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

NATHAN MCGHEE, ) ) Plaintiff, ) ) vs. ) Case No. 21-cv-678-NJR ) ) CHRISTINA NOTTINGHAM, ) REBECCA WALTON, ADAM ) DUNCAN, and FIELD SERVICE ) DEPARTMENT, ) ) Defendants. )

MEMORANDUM AND ORDER ROSENSTENGEL, Chief Judge: Plaintiff Nathan Mcghee, an inmate of the Illinois Department of Corrections (“IDOC”) who is currently incarcerated at Shawnee Correctional Center,1 brings this action for deprivations of his constitutional rights pursuant to 42 U.S.C. § 1983. In his Complaint (Doc. 1), Mcghee alleges his parole was improperly revoked and he faced unconstitutional conditions of confinement. He seeks declaratory judgment and monetary damages. This case is now before the Court for preliminary review of the Complaint pursuant to 28 U.S.C. § 1915A. Under Section 1915A, the Court is required to screen

1 The docket indicates that Mcghee is currently at Shawnee Correctional Center, but a review of IDOC’s inmate search indicates he is now at Stateville Correctional Center. See IDOC Inmate Search, https://www2.illinois.gov/idoc/Offender/Pages/InmateSearch.aspx (last visited March 1, 2022). prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a). Any portion of a complaint that is legally frivolous, malicious, fails to state a claim upon which

relief may be granted, or asks for money damages from a defendant who by law is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). The Complaint

Mcghee makes the following allegations in the Complaint (Doc. 1): On or about September 11, 2020, Mcghee was subject to a lie detector test in Marion County, Indiana, and Adam Duncan falsified a probation violation report against Mcghee (Id. at p. 9). Duncan requested that Mcghee be arrested and returned to custody in Illinois (Id.). On October 26, 2020, Mcghee was apprehended in Indiana and held in an Indianapolis, Indiana, jail until November 12, 2020 (Id.). On October 29, 2020, Christina Nottingham and Rebecca Walton signed an IDOC warrant for his arrest on a parole violation (Id.). On October 12, 2020, he was transferred to IDOC at Stateville Correctional Center/NRC

where he remained until March 1, 2021 (Id. at p. 10). Mcghee notes during this time the coronavirus pandemic was ongoing. He also notes that on December 15, 2020, the Prison Review Board resumed his parole. Mcghee alleges the parole violation warrant included false allegations and that Nottingham and Walton signed their approval to those allegations (Id.).

Mcghee further alleges that “agents” of the Field Service Department refused to investigate his proposed home site (Id. at p. 10). As a result, he remained in IDOC custody from December 15, 2020, until the date he filed his Complaint (Id.). He alleges all Defendants acted with deliberate indifference in keeping him in IDOC custody in the middle of an ongoing pandemic due to the false allegations.

Mcghee alleges he was subject to an unreasonable search and seizure by Defendants unlawfully arresting and keeping him in IDOC custody on a false parole violation (Id. at p. 12). They also failed to approve or deny his homesite within the allotted time after his parole was approved by the Prison Review Board (Id. at p. 13). He alleges that continuing to keep him housed in IDOC violates his due process rights. He also alleges that he was subject to cruel and unusual punishment by being held in IDOC

custody during the middle of an ongoing pandemic (Id. at p. 12). He describes the conditions as inhumane and unsafe, and notes he was unable to practice social distancing during the pandemic (Id. at p. 13). Discussion

There are a number of issues with Mcghee’s Complaint. To the extent Mcghee alleges that his parole violation was based on false allegations those claims are barred by Heck v. Humphrey, 512 U.S. 477 (1994). Heck prohibits a litigant from bringing a damages claim under Section 1983 that would necessarily invalidate a conviction or sentence, unless the conviction or sentence had been previously set aside in another proceeding. The Seventh Circuit has specifically applied the Heck bar in circumstances similar to

Mcghee’s circumstances. See Hadley v. Quinn, 524 F. App’x 290, 293-94 (7th Cir. 2013) (Heck applied to complaint that parole board improperly revoked plaintiff’s parole); Brown v. Hackbarth, 445 F. App’x 865, 867 (7th Cir. 2011) (prisoner alleged parole board considered false information in his record in denying him parole); Knowlin v. Thompson, 207 F.3d 907, 909 (7th Cir. 2000) (Heck barred consideration of plaintiff’s claims that he was improperly extracted from another state on parole violation warrant); Antonell v. Fosteri, 104 F.3d 899,

900 (7th Cir. 1997) (plaintiff arrested on allegedly invalid parole violator warrant and claimed documentation of warrant was inadequate). Therefore, Mcghee cannot proceed with a Section 1983 claim for money damages against the defendants until the Prison Review Board’s decision is overturned or invalidated. Although a plaintiff may challenge his continued confinement in a federal habeas corpus action, he must first present all of his claims to the Illinois courts. This includes appealing any adverse decision to the

Illinois Appellate Court and the Illinois Supreme Court. Thus, his claims against his parole officers are barred by Heck and shall be DISMISSED without prejudice to any subsequent state or federal claim Plaintiff wishes to pursue. To the extent he argues that the Field Service Department violated his Eighth Amendment, and possibly Fourteenth Amendment due process rights by failing to

approve or deny his home sites, the Illinois Field Service Department is not a “person” within the meaning of the Civil Rights Act and is not subject to a Section 1983 action. See Will v. Mich. Dep’t of State Police, 491 U.S. 58, 71 (1989). Mcghee also fails to identify any individual that he contacted about his home sites or who at the Field Service Department was responsible for investigating his proposed sites. He just alleges that the Prison

Review Board, though finding him guilty of the violations, approved his release (Doc. 1, p. 46) but his home sites have not been investigated. Without more information, Mcghee does not presently state a claim regarding his home site. Childress v. Walker, 787 F.3d 433, 439 (7th Cir. 2015) (“A plaintiff states a claim for an Eighth Amendment violation if he is detained in jail for longer than he should have been due to the deliberate indifference of corrections officials.”).

Further, as to Mcghee’s condition of confinement claim, he merely alleges in conclusory fashion that he was housed in ways that prevented social distancing in the middle of a pandemic. In order to state a viable conditions of confinement claim, Mcghee must allege facts that satisfy both the objective and subjective components of an Eighth Amendment cruel and unusual punishment claim.

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Related

Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Michael C. Antonelli v. William T. Foster
104 F.3d 899 (Seventh Circuit, 1997)
Rudolph Lucien v. Diane Jockisch
133 F.3d 464 (Seventh Circuit, 1998)
Lee Knowlin v. Pat Thompson and Ed Michalek
207 F.3d 907 (Seventh Circuit, 2000)
Anthony Riccardo v. Larry Rausch
375 F.3d 521 (Seventh Circuit, 2004)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Craig Childress v. Roger Walker, Jr.
787 F.3d 433 (Seventh Circuit, 2015)
Brown v. Hackbarth
445 F. App'x 865 (Seventh Circuit, 2011)
Hadley v. Quinn
524 F. App'x 290 (Seventh Circuit, 2013)

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McGhee v. Nottingham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcghee-v-nottingham-ilsd-2022.